If there are two companies whose FCPA settlements serve as textbook examples of the government’s steely expectations for third-party compliance, they’re Walmart and Ericsson.
So says Kara Brockmeyer, partner at Debevoise and Plimpton and former Chief of the Foreign Corrupt Practices Act (FCPA) Unit at the U.S. Securities and Exchange Commission (SEC). Brockmeyer delivered the keynote address at the Third-Party Risk Management and Oversight Summit, hosted by Compliance Week and Foundation Research Associates (FRA) in San Francisco this week.

